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International

  • June 19, 2018

    IRS’ Bid for Tax Data Doesn't Flout EU Law, Official Says

    Airbnb and other rental platforms do not appear to be violating European Union data protection rules when they give the Internal Revenue Service basic taxpayer information on EU citizen hosts and their guests, European Tax Commissioner Pierre Moscovici said.

  • June 19, 2018

    OECD, African Tax Administrators Renew Cooperation Pact

    The OECD and the African Tax Administration Forum on Tuesday renewed their cooperation agreement on making tax systems in Africa fairer and more efficient, the groups said in a statement.

  • June 19, 2018

    UK Must Determine Post-Brexit Tax Policy, Lawmakers Say

    British lawmakers asked the government Tuesday to decide how closely it wants to stay aligned with European tax norms even as the European Commission warned the country it could lose market access or be branded a tax haven if it competes unfairly.

  • June 19, 2018

    EU Antitrust Chief Sees Global Progress Curbing State Aid

    The European Union’s top competition enforcer touted progress Tuesday in getting countries outside the EU to avoid picking economic winners and losers through “harmful subsidies,” part of her efforts to take the bloc's state aid rules global.

  • June 18, 2018

    OECD Draft Warns Resource-Rich Countries On Incentives

    Resource-rich countries looking to lure investment through tax incentives run the risk of encouraging profit shifting, according to OECD guidance released Monday.

  • June 18, 2018

    Oil Co. Loses Bid To Recoup $17.7M Tax Refund For Bad Debt

    A Texas federal judge handed the Internal Revenue Service a quick win Monday in a suit brought by oil field services company Baker Hughes Inc. seeking to recover $17.65 million in taxes it claims should have been allowed as a deduction for a bad debt made before it acquired BJ Services Co. in 2009.

  • June 18, 2018

    ‘Reference Sets’ Could Speed Up Transfer Pricing Cases

    The IRS is trying to create a “reference set library” of comparable company data used as benchmarks in transfer pricing cases — a move tax practitioners said could save time in audits or advance pricing agreements.

  • June 18, 2018

    OECD's Tax Treaty Rules Cast Uncertainty In Latin America

    The Organization for Economic Cooperation and Development's global agreement to implement its anti-tax avoidance recommendations casts uncertainty over existing business arrangements in Latin America that may not hold up under new treaty-shopping rules, practitioners said at a recent tax conference in Miami.

  • June 18, 2018

    Lawyers Criticize UK Tax Authority’s 'Aggressive' Stance

    U.K. tax officials have shifted over the last decade from strictly following rules to maximizing revenue yields, taking a tougher line on penalties, information collection and litigation and potentially making the system less fair, legal specialists told a parliamentary committee Monday.

  • June 18, 2018

    Foreign Co. Not A Legitimate Insurer, Tax Court Says

    A company incorporated as an insurer in the West Indies was ruled to be a foreign corporation engaged in transactions that are not insurance contracts, the U.S. Tax Court said in a Monday ruling that also found the company liable for tax on U.S.-source income.

  • June 18, 2018

    IRS Asks 5th Circ. To Deny Individual $53M Shelter Loss

    The Internal Revenue Service has asked the Fifth Circuit to uphold a U.S. Tax Court decision that found that an almost $53 million loss could not be considered deductible because it lacked economic substance.

  • June 18, 2018

    Tax Concepts Must Change For Digital Economy: EU Official

    European Union lawmakers’ understanding of corporate taxation needs to change fundamentally in view of an increasingly digital economy, a top European Commission official said Monday, pointing to the wide discrepancy in tax paid by digital companies and conventional ones.

  • June 15, 2018

    EU Renewing 2-Step Process For Common Tax Base Project

    The European Commission will relaunch its project for a common consolidated corporate tax base, or CCCTB, as a two-step process, with the "consolidated" aspect removed in the first step, it said in a statement Friday.

  • June 15, 2018

    Corp. Counsel Group Backs Mining Co. In $207M Tax Row

    The Association of Corporate Counsel urged a California federal court to consider communication privileges Thursday, backing Canadian mining company Silver Wheaton Corp. in a class action brought by investors over the company’s alleged scheme to keep $207 million in transfer pricing tax liability secret to boost stock prices.

  • June 15, 2018

    Hawaii Updates Fed. Tax Conformity, Splits On Foreign Income

    Hawaii’s governor has signed a bill that conforms most of the state’s income, estate and generation-skipping transfer tax laws with provisions of the federal tax overhaul but decouples from federal code for tax treatment of foreign income from intellectual property.

  • June 15, 2018

    Taxation With Representation: Wachtell, Shearman, Simpson

    In this week’s Taxation with Representation, KKR bought Envision Healthcare for $9.9 billion, Gebr. Knauf KG bought rival USG Corp. for $7 billion, Blackstone bought Investa Office Fund for $2.3 billion and Royal Caribbean Cruises scooped up Silversea Cruises for $1 billion.

  • June 15, 2018

    Tax Data Privacy May Outweigh Possible EU Fines, Atty Says

    The European Union’s proposed requirement for large multinational companies to publicly disclose how much tax they pay around the world would need to come with hefty fines to outweigh the desire to protect sensitive information, a tax practitioner recently said at a tax conference in Miami.

  • June 15, 2018

    Germany Won’t Charge Interest On Some Late Taxes, For Now

    Germany’s Finance Ministry said Thursday it would abide by a recent court ruling indicating companies don’t have to pay interest on late tax payments, but tax specialists recommended a cautious approach, noting that the issue isn’t ultimately resolved.

  • June 14, 2018

    Congo Must Pay $96M Customs Contract Award, Suit Says

    A U.S. company that helps the governments of developing nations modernize their customs and tax administrations has won a more than $96 million arbitral award against the Democratic Republic of the Congo, according to documents filed Thursday asking a D.C. federal court to confirm the award.

  • June 14, 2018

    France's Social Tax Not An Illegal Customs Duty, ECJ Rules

    The European Court of Justice's Fourth Chamber dismissed a challenge to France's social contribution tax by a French lubricant additive company, ruling it was not an illegal customs duty in a decision released Thursday.

Featured Stories

  • SEC Roundup: Big US Cos. Book $140B In Repatriation Tax

    No Photo Available

    Since enactment of the U.S. tax overhaul, 66 public companies in the Fortune 500 have set aside $140 billion to pay the law’s levy on repatriated past earnings from foreign subsidiaries, according to corporate regulatory filings. Here, Law360 Tax Authority looks at what companies have said about the tax law’s foreign income provisions in recent reports to shareholders.

  • EU's $5.5B Tax Break Helps E-Book Sector, Moscovici Says

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    A proposed European Union value-added tax break that could mainly benefit big web platforms shows the bloc is not out to get U.S. digital firms, European Tax Commissioner Pierre Moscovici told Law360 in an exclusive interview, despite his stated aim to increase the tax take from the digital sector.

  • EU Will Continue Fight For Digital Tax, Moscovici Says

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    The European Union will continue its efforts to tax the worlds largest digital companies despite key countries' reservations about the proposal and concerns that it could hurt the EU's competitiveness, the European Commission's top tax official, Pierre Moscovici, said in an exclusive interview with Law360.

Expert Analysis

  • Opinion

    Oregon Should Reinstate Its Tax Haven Law

    Michael M.jpg

    Repeal of the Oregon tax haven provision was an unwarranted giveaway to profitable multinational corporations that are exploiting foreign tax havens to shift profits earned in Oregon beyond the tax reach of the state. The law should be reinstated, says Michael Mazerov of the Council on Budget and Policy Priorities.

  • How Turkey's Expansive New Tax Amnesty Law Works

    Hakan Eraslan

    Hakan Eraslan of White & Case LLP discusses a detailed new amnesty law recently enacted in Turkey, which offers taxpayers a broad amnesty for most types of unpaid taxes.

  • Mazzei Case Educed An Unusual Tax Court Response

    Lawrence Hill

    The U.S. Tax Court yet again showed itself to be an unfavorable forum for litigating tax-advantaged transactions with its decision in Mazzei v. Commissioner of Internal Revenue — deciding the taxpayers' foreign sales corporation structure lacked economic substance. However, this decision was particularly notable in featuring a rare Tax Court dissent, say Lawrence Hill and Kevin Platt of Winston & Strawn LLP.

  • A Look At Treasury's Recent Efforts To Reform Regulation

    Andrew Roberson

    In keeping with the "one in, two out" principle of deregulation adopted by the Trump administration, the president has called on the U.S. Department of the Treasury to reduce regulatory burdens on taxpayers. Andrew Roberson and Justin Crause at McDermott Will & Emery LLP look at what has happened so far and what taxpayers can do in anticipation of future regulatory reform.

  • The 965 Tax: What Congress Giveth, Can IRS Taketh Away?

    Carlos Somoza

    A recently announced IRS position that surprised many tax practitioners is inconsistent with the plain language of Internal Revenue Code Section 965 and congressional intent — and creates problems for both individual and corporate taxpayers, says Carlos Santos of Kaufman Rossin PA.

  • Spotlight On EU's Bold New Digital Economy Tax Ideas

    Stefanie Hardy

    As the Organization for Economic Cooperation and Development attempts to craft a new digital services tax, two major concerns are the impact of the tax on U.S. companies operating within the European Union, which are estimated to make up approximately half the companies that would be hit by the tax, and the deterrence of high-tech investment in the EU, says Stefanie Hardy of Nauta Dutilh.

  • Tax Law Shake-Ups In Swiss Wealth Management

    Marnin Michaels

    There have been a number of notable developments in the past 12 months that are relevant to the wealth management industry in Switzerland. Attorneys at Baker McKenzie discuss the common reporting standard and Swiss corporate tax reform, among other issues.

  • 5 Tips For Defending An Accounting Malpractice Claim

    Nathan Novak

    Having a client who owes the IRS more money than expected because they relied on faulty advice is every tax adviser's worst fear, but nobody's perfect. Tax advisers should consider five factors before conceding liability and reaching for their checkbooks, says Nathan Novak at Orrick Herrington & Sutcliffe LLP.

  • The Principal Purpose Test — A US Tax Court Preview

    Rusudan Shervashidze

    The IRS argument in a case pending before the U.S. Tax Court was similar to the principal purpose tests laid out by the Organization for Economic Cooperation and Development and the European Commission. To that extent, European and Canadian tax advisers who face application of a principal purpose test under domestic law or a tax treaty should take note of the court's ruling, say Rusudan Shervashidze and Stanley Ruchelman of Ruchelman PLLC.

  • How To Minimize US Tariff Impact On Construction Projects

    Jason McLarry

    The new U.S. tariffs on steel and aluminum imports bring a number of questions for construction project stakeholders currently locked into fixed price contracts, but certain contract provisions such as those relating to changes in law and force majeure may allow them to mitigate the tariffs' financial consequences, say attorneys at Troutman Sanders LLP.